Building more accurate and effective greenhouse gas accounting

The next decade is critical in limiting global warming, and companies have a central role to play. Accurate, comprehensive and actionable corporate greenhouse gas (GHG) inventories are essential to help companies understand their GHG footprints and determine how to mitigate emissions to advance a carbon-free economy.

The Greenhouse Gas Protocol (GHGP) is the world’s most established and widely used GHG accounting standard, serving as the foundation for the private sector’s most prominent carbon disclosure platforms and clean energy leadership programs. It has helped thousands of companies calculate and report their GHG emissions, and provided valuable information that has helped them develop strategies to reduce them.

Today, we’re submitting comments in response to an open survey on the future of the GHGP. Updating the GHGP will drive continued improvements in the accuracy of companies’ GHG inventories, providing useful information that enables them to make decisions and take actions that drive real, measurable GHG reductions.

This is a high priority for Google because we measure our footprint not only to better understand it, but also to inform how we reduce it. For example, since we set our goal of operating our data center and office campuses on 24/7 carbon-free energy by 2030, we have been working to build a more granular understanding of the availability of carbon-free energy on the electricity grids that serve us, so we can maximize the effectiveness of our clean energy purchasing in both reducing our carbon emissions and accelerating grid decarbonization.

Our submission focuses most heavily on how companies track emissions related to their use of electricity. This reflects the importance of electricity to Google’s operations, the central role of clean electricity in reducing global GHG emissions, and the relative maturity of standards and guidance in this area. Drawing on a wealth of academic research and our experience as a global clean energy buyer, we identify practical improvements that would increase the accuracy and usefulness of accounting standards for electricity-related emissions, better align accounting metrics with the physical realities of electricity grids, and equip companies with the information they need to make informed decisions about how to reduce emissions.

Our comments conclude with a brief discussion of emissions from companies’ value chains — from supply chains all the way to the use of products downstream. We highlight areas where we believe that improvements are possible today, and identify issues where further research, experimentation and stakeholder engagement would be beneficial.

Across all our comments, we encourage the GHGP to build strong governance systems and operate with agility, so that it can continue to iterate and evolve in response to changing technologies, markets and corporate practices.

Addressing climate change requires creative and ambitious solutions, and GHG accounting standards have a critical role to play. We welcome the opportunity to share our ideas on the future of the GHGP, and look forward to working with our partners and stakeholders to support practical and effective improvements.